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Bulletin: 20/2
Batch: 261
Reference: 35189
Product: Makeup
Advertiser: Inglot Cosmetics Limited / Chloe Ormond
Influencer:
Agency:
Medium: Internet (Social Media)
Codes:
ASAI Code 7th Edition: 2.4(c), 3.31, 3.32
An Instagram story by Chloe Ormond for Inglot Cosmetics featured frames of various Inglot products. While some of the frames had referred to the fact that the posts were sponsored posts, some had not. For example, one post referred to the following:
“The power of a nice colour lippy & gloss #SP @ inglotireland.”
Another post featured an image of the Influencer after using the products and read:
“So simple & it’s literally all I do”
Issue 1
The complainant said that she initially considered the story to be a make-up tutorial. She said that some of the posts were then identified as being sponsored posts with #SP while some of the posts were not identified as such. She said that it was difficult to decipher what posts were advertising material and what were not.Issue 2
The complainant said that where the posts were identified as being sponsored that it was difficult to read the #SP at times as the writing appeared to be the same colour as what the influencer was wearing.The advertisers said that before engaging with the Influencer, they had provided her with a brief to follow which had included a section on advertising guidelines. They informed her that in line with the ASAI Code that all posts had to be clearly marked as being sponsored.
The advertisers said they had also asked the Influencer to ensure the “Paid Partnership with Inglot Ireland” was visible across all posts and had provided her with a link to the ASAI’s guidelines for bloggers for reference.
In conclusion the advertisers said that when undertaking work with all influencers, they advised them to ensure that they followed ASAI Guidelines in relation to all social media posts. They said they had spoken with the Influencer’s agency in the matter and would discuss, with all agencies representing influencers in greater detail, the importance of identifying marketing communications appropriately.
The agency representing the Influencer apologised for the fact that not every single frame of her story had been identified appropriately with #SP.
The agency said that the story had been a paid for collaboration with Inglot which had contained approximately 20 frames. They said that the Influencer was relatively new to this type of advertising and it had been human error that each post had not been identified
appropriately. They said the Influencer was extremely sorry for the error which had occurred on this occasion and that as her agent they would ensure that similar errors do not re-occur in the future.
Complaint upheld in part.
Issue 1 - Upheld
The Complaints Committee considered the detail of the complaint and the responses received. The Committee noted that while some of the Instagram story posts had been identified as advertising material, not all had been hash tagged appropriately to indicate that they were marketing communications. In the circumstances, the Committee considered that the posts which had not been hash tagged properly were in breach of Section 3.31 and 3.3.2 of the Code.Issue 2 – Not Upheld
The Complaints Committee noted that where the posts which had been hash tagged as advertising material with #SP the contrast had varied against the background, with one being slightly less legible than the other. Overall, however, they considered they were legible and did not consider that the Code had been breached in this regard.ACTION REQUIRED:
The Committee reminded all advertisers to ensure that all relevant social media posts for their brand had appropriate hash tags where necessary.